Willett v. United States

Plaintiffs here seek to “make a new case”, that is, they wish to obtain for the same transaction different tax consequences than were meted ’out by the Tax Court, and on appeal, by the Sixth Circuit, to other copartners who sought judicial review by different route. Willett v. Commissioner, *79016 CCH Tax Ct. Mem. 840 (1957), supp. opinion, 17 CCH Tax Ct. Mem. 93 (1958), aff'd, 277 F. 2d 586 (6th. Cir.), cert. denied, 364 U.S. 914 (1960). Naturally, those decisions are entitled to a high degree of respect as stare decisis here except insofar as new evidence destroys some of their factual…